On October 08, 2019 a
Request,Application
was filed
involving a dispute between
Acosta, Sandy,
Jetcruzer International, Llc.,
and
Acosta, Sandy,
Does 3 Through 50,
Guzman, Marvin J.,
Zepeda, Ulises A.,
for Fraud
in the District Court of San Bernardino County.
Preview
F I L E D
SUPERIOR COURT OF cmroamA
David M. Shaby II, Esq. (97871) cgmgggggggggfio
dshaby@shabyandassoc1ates.com
R. Chrlstopher Harshman, Esq. (248214)
MAY 2 6 2321
charshman@shabyandassociates.com
DAVID M. SHABY II & ASSOCIATES, APC
11949 Jefferson Boulevard, Suite 104 BY
O\U1-§WN
Culver City, California 90230 DEBRA PEDROSA, DEPUTY
Telephone: 827-7171
E310;
Facs1mile: 310 822-8529
A ttomgrsfor Defendant and Cross-Complaz'nant Sandy Acosta
SUPERIOR COURT 0F CALIFORNIA
COUNTY 0F SAN BERNARDINO
Jetcruzer International, LLC, Case no. CIVDSI930132
plaintiff,
Assigned to the Hon. Tom Garza, Dept. 327
REQUEST To SUBMIT SUPPLEMENTAL
VS.
DECLARATION, UNDER SEAL, IN SUPPORT 0F
Sandy Acosta, e, a1,
MOTION T0 COMPEL FURTHER RESPONSES
Date: June 9, 2021
Defendants.
Time: 9:00 am.
And Related Cross—Complaint Department: 827
Complaint filed: October 8, 2019
16
Trial date: February 7, 2022
17
18 Defendant and cross—complainant Sandy Acosta hereby requests the Court permit the
19 submission of the Supplemental Declaration of R. Christopher Harshman in Support of her Motion to
20 Compel Further Responses set to be heard on June 9, 2021 (the “Supp. Decl. ”). The Supplemental
21 Declaration includes evidence highly relevant to the pending motion (Supp. Decl.‘[[‘{[ 2—5), which was
22 not available at the time the motion was filed (Supp. Declfll S). Counsel for plaintiff and cross-defendant
23 JetCruzer International, LLC (“JetCruzer”) was provided with a courtesy copy of this evidence on May
24 14, 2021 (Supp. Decl. WI 14), and this specific piece of evidence early in the afternoon ofMay 25, 2021,
25 before jetCruzer’s opposition to the motion was due (Id). Although the parties intend to have a
26 stipulated protective order in place (Id. ‘fl 8), that has not yet been finalized.
27 Nevertheless, JetCruzer has raised at least colorable privacy concerns concerning this evidence,
28 which can be an “overriding interest” recognized under California law.
1
REQUEsr '1‘0 SUBMIT SUPPLEMENTAL DECLARATION (UNDER SEAL)
Document Filed Date
May 26, 2021
Case Filing Date
October 08, 2019
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
F I L E D SUPERIOR COURT OF cmroamA David M. Shaby II, Esq. (97871) cgmgggggggggfio dshaby@shabyandassoc1ates.com R. Chrlstopher Harshman, Esq. (248214) MAY 2 6 2321 charshman@shabyandassociates.com DAVID M. SHABY II & ASSOCIATES, APC 11949 Jefferson Boulevard, Suite 104 BY O\U1-§WN Culver City, California 90230 DEBRA PEDROSA, DEPUTY Telephone: 827-7171 E310; Facs1mile: 310 822-8529 A ttomgrsfor Defendant and Cross-Complaz'nant Sandy Acosta SUPERIOR COURT 0F CALIFORNIA COUNTY 0F SAN BERNARDINO Jetcruzer International, LLC, Case no. CIVDSI930132 plaintiff, Assigned to the Hon. Tom Garza, Dept. 327 REQUEST To SUBMIT SUPPLEMENTAL VS. DECLARATION, UNDER SEAL, IN SUPPORT 0F Sandy Acosta, e, a1, MOTION T0 COMPEL FURTHER RESPONSES Date: June 9, 2021 Defendants. Time: 9:00 am. And Related Cross—Complaint Department: 827 Complaint filed: October 8, 2019 16 Trial date: February 7, 2022 17 18 Defendant and cross—complainant Sandy Acosta hereby requests the Court permit the 19 submission of the Supplemental Declaration of R. Christopher Harshman in Support of her Motion to 20 Compel Further Responses set to be heard on June 9, 2021 (the “Supp. Decl. ”). The Supplemental 21 Declaration includes evidence highly relevant to the pending motion (Supp. Decl.‘[[‘{[ 2—5), which was 22 not available at the time the motion was filed (Supp. Declfll S). Counsel for plaintiff and cross-defendant 23 JetCruzer International, LLC (“JetCruzer”) was provided with a courtesy copy of this evidence on May 24 14, 2021 (Supp. Decl. WI 14), and this specific piece of evidence early in the afternoon ofMay 25, 2021, 25 before jetCruzer’s opposition to the motion was due (Id). Although the parties intend to have a 26 stipulated protective order in place (Id. ‘fl 8), that has not yet been finalized. 27 Nevertheless, JetCruzer has raised at least colorable privacy concerns concerning this evidence, 28 which can be an “overriding interest” recognized under California law. 1 REQUEsr '1‘0 SUBMIT SUPPLEMENTAL DECLARATION (UNDER SEAL)